EL PASO, Texas (KTSM) -- The City of El Paso filed an amended petition requesting a temporary and permanent injunction against RCI Holdings – owners of Chicas Locas, formerly known as Jaguars Gold Club.  County Attorney’s Office seeks to shut down ‘Chicas Locas’ In court documents obtained by KTSM, the petition alleges Chicas Locas is guilty of sexually oriented business (SOB) violations and state law violations.   The document reads in part:  “Defendant has a clear track record of disregard for the law and of being a source of significant criminal activity. Undoubtedly RCI will argue that the court should take its word – scouts honor – it will refrain from sponsoring, causing, or permitting any further illicit activity.”  The City’s petition provides two examples where RCI’s other businesses in Houston and Odessa were issued temporary injunctions and raided for similar offenses as Jaguars – stating RCI’s unlikeliness to operate Chicas Locas as a "bikini bar." Former Jaguars location opens as ‘Chicas Locas’ Attorneys for the City also submitted 34 pieces of evidence that include SOB violations, lack of licenses required by the City's Code, noncompliance with the Texas Alcoholic Beverage Code, along with a list of 180 calls for service within a one-year period that reference a range of crimes.  Within the evidence filings, exhibit "L" entails a witness statement given by an El Paso Police Department (EPPD) detective that testifies he entered the establishment on Sept. 19, undercover to observe if any SOB violations or prostitution offenses were being committed.  The detective says he was approached by a female employee who sat on his lap and offered him a private dance, to which he agreed to. His statement reads in part:  “(She) escorted me to a private VIP area where I paid a $20 initial VIP entrance fee. While in the VIP area, I sat down on a private sofa where she began to dance proactively. (She) climbed on top of me while removing her top and exposing her breasts.”  The detective goes on to detail how the dancer began guiding his hands in a provocative manner and said she would expose herself more if the detective paid more money.  KTSM spoke with RCI Holdings lead attorney for the case, Casey Wallace, who said litigation is unfounded.  “Chicas Locas is operating as a club. It is not operating as a sexually oriented business,” Wallace said.  Wallace said his clients want to work with the County and the City of El Paso to be good corporate citizens. He said his clients have been compliant with code requests.  In a statement to KTSM the City said:  “At this time, the establishment has submitted plans for the installation of the fire alarm systems and sprinkler system. Also at this time, the establishment has not applied for an SOB license, which would be required if they are planning on operating as an SOB. The establishment has not submitted any permit applications for the repairs to the electrical or plumbing systems; there is no application for a fire assembly license; and there is no application for a food serving establishment. They have applied for an alcohol license; however, it is not showing up on the TABC website and it is unclear if they plan to operate as a BYOB.”  RCI Holdings has separate hearings with both government entities. The first with the City on Oct. 15., then with the County on Oct. 16.